Attorneys And Doctors In New York Charged With Defrauding Businesses And Insurance Companies Of More Than $31 Million Through Trip-And-Fall Fraud Scheme

 

 Audrey Strauss, the United States Attorney for the Southern District of New York, and Michael J. Driscoll, the Assistant Director-in-Charge of the New York Office of the Federal Bureau of Investigation (“FBI”), announced today the unsealing of an Indictment charging GEORGE CONSTANTINE, MARC ELEFANT, ANDREW DOWD, and SADY RIBEIRO with conspiracy to commit mail and wire fraud, mail fraud, and wire fraud in connection with a scheme to obtain fraudulent insurance reimbursements and other compensation for fraudulent trip-and-fall accidents.  ELEFANT, DOWD, and RIBEIRO were arrested earlier this morning and will be presented today before United States Magistrate Kevin Nathaniel Fox in Manhattan federal court.  CONSTANTINE is expected to surrender and be presented in Manhattan federal court tomorrow.  The case has been assigned to United States District Judge Loretta A. Preska.

Manhattan U.S. Attorney Audrey Strauss said: “As alleged, the defendants abused their professional licenses and positions of trust to steal millions of dollars from New York City businesses and their insurance companies through a massive trip-and-fall fraud scheme.  In carrying out the scheme, the defendants allegedly preyed upon the most vulnerable members of society.  Now, thanks to the FBI, the defendants are in custody and facing federal charges.”

FBI Assistant Director-in-Charge Michael J. Driscoll said: “The scheme allegedly carried about by the defendants charged today highlights the extent to which some are willing to go in the name of money.  Licensed attorneys are well aware of their obligation to uphold the law.  As we allege today, they did just the opposite, stealing from business owners and preying upon other vulnerable victims who were coerced into risking their own personal health and safety.  This alleged conduct is beyond reprehensible, and something we won’t let people get away with.”

As alleged in the Indictment unsealed today in Manhattan federal court[1]:

From in or about January 2013, up to and including in or about April 2018, the defendants engaged in an extensive fraud scheme through which the defendants defrauded businesses and insurance companies by staging trip-and-fall accidents and filing fraudulent lawsuits arising from those staged trip-and-fall accidents.  In or about 2015, certain members of the fraud scheme split from the original conspiracy and formed a separate conspiracy that operated in substantially the same manner.  GEORGE CONSTANTINE was the primary attorney who filed fraudulent lawsuits in the original conspiracy starting in 2013.  MARC ELEFANT was the primary attorney who filed fraudulent lawsuits in the separate conspiracy, formed in or about 2015.

Fraud scheme participants recruited individuals (the “Patients”) to stage or falsely claim to have suffered trip-and-fall accidents at particular locations throughout the New York City area (the “Accident Sites”).  In the course of the fraud scheme, scheme participants recruited more than 400 Patients.  In the beginning, scheme participants would instruct Patients to claim they had tripped and fallen at a particular location, when in fact the Patients had suffered no such accidents.  Eventually, at the direction of the lawyers who filed fraudulent lawsuits on behalf of the Patients, scheme participants began to instruct Patients to stage trip-and-fall accidents, i.e., to go to a location and deliberately fall.  Common Accident Sites used during the fraud scheme included cellar doors, cracks in concrete sidewalks, and purported “potholes.”

After the staged trip-and-fall accidents, Patients were referred to specific attorneys, including GEORGE CONSTANTINE and MARC ELEFANT, who would file personal injury lawsuits (the “Fraudulent Lawsuits”) against the owners of the Accident Sites and/or insurance companies of the owners of the accident sites (the “Victims”).  The Fraudulent Lawsuits did not disclose that the Patients had deliberately fallen at the accident sites or, in some cases, had not fallen at all.  During the course of the fraud scheme, the defendants, together with others known and unknown, attempted to defraud the Victims of more than $31,000,000.

The Patients were also instructed to receive ongoing chiropractic and medical treatment from certain chiropractors and doctors, including ANDREW DOWD and SADY RIBEIRO.  The fraud scheme participants advised the Patients that if they intended to continue with their lawsuits, they were required to undergo surgery.  As an incentive to getting surgery, the recruited Patients were offered a payment of typically between $1,000 and $1,500 after they completed surgery (“Post-Surgery Payments”).  Patients generally were told to undergo two surgeries.

Doctors in the fraud scheme, including DOWD and RIBEIRO, were expected to, and in fact did, conduct these surgeries regardless of the legitimate medical needs of the Patients.  For example, in a March 2016 email, before DOWD examined the shoulder of a particular Patient who had staged a trip-and-fall accident (“Patient-2”), one of the scheme organizers asked DOWD to “write us an additional report today stating that [Patient-2’s] Lt. shoulder has worsened [so that I can] book this surgery for you.”  DOWD provided the requested report and recommended that Patient-2 undergo arthroscopic surgery. 

Likewise, in an August 2015 email from RIBEIRO to the owner of a litigation funding company, in which RIBEIRO described the services that he performed, RIBEIRO wrote, “I will play very honest ‘game’ with you . . . I see the patient and I generate a very good dictation that justifies the treatment-there is a cost for that and I hope a profit.”

Members of the fraud scheme often recruited individuals who were extremely poor as Patients – individuals desperate enough to submit to surgeries in exchange for the small Post-Surgery Payments.  For example, it was common for Patients to ask for food when they would appear for their intake meetings with the lawyers.  Many of the Patients did not have sufficient clothing to keep them warm during the wintertime and had poor-quality shoes.  Members of the fraud scheme also recruited Patients who were drug addicts.  It was also common for scheme participants to recruit Patients from homeless shelters in New York City.

The Patients’ legal and medical fees were usually paid for by litigation funding companies (the “Funding Companies”), even if the Patient maintained medical coverage through an insurance company or a government-subsidized program.  The Funding Companies also paid the fraud scheme organizers and participants referral fees, typically $1,000 to $2,500, for each Patient who signed a funding agreement.  In exchange for funding Patients’ medical and legal costs, the Funding Companies charged the Patients high interest rates, sometimes up to 50% on medical loans and up to 100% on personal loans.  The interest rates were so high that oftentimes the majority (if not all) of the proceeds that were awarded in the Fraudulent Lawsuits were paid to the Funding Companies, CONSTANTINE, ELEFANT, DOWD, RIBEIRO, and others, with the Patients receiving a much smaller percentage of the remaining recovery.

GEORGE CONSTANTINE, 58, and MARC ELEFANT, 49, are New York-licensed attorneys who represented hundreds of Patients and filed Fraudulent Lawsuits on their behalf as part of the fraud scheme.

ANDREW DOWD, 45, is a New York-licensed orthopedic surgeon who performed hundreds of knee and shoulder surgeries on Patients as part of the fraud scheme, earning approximately $9,500 per surgery.

SADY RIBEIRO, 51, is a New York-licensed pain management doctor and surgeon who performed back surgeries, among other medical procedures, on Patients.  RIBEIRO paid participants cash kickbacks in exchange for patient referrals and treated nearly 200 Patients during the fraud scheme.

GEORGE CONSTANTINE, MARC ELEFANT, ANDREW DOWD, and SADY RIBEIRO are each charged with conspiracy to commit mail and wire fraud, which carries a maximum sentence of 20 years in prison, mail fraud, which carries a maximum sentence of 20 years in prison, and wire fraud, which carries a maximum sentence of 20 years in prison.  DOWD and RIBEIRO are also charged with one additional count each of conspiracy to commit mail and wire fraud, mail fraud, and wire fraud.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencings of the defendants will be determined by the judge.   

Ms. Strauss praised the outstanding investigative work of the New York FBI.  Ms. Strauss also thanked the National Insurance Crime Bureau for their assistance in the investigation. 

The charges contained in the Indictment are merely accusations, and the defendants are presumed innocent unless and until proven guilty.                       

[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described should be treated as an allegation.

Rep. Jamaal Bowman Statement on House Passage of FY 2022 Budget Resolution

 

 Rep. Jamaal Bowman issued the following statement Wednesday after voting “yes” to pass the budget resolution:

“Americans voted for a House, Senate and White House that would expand health care, improve educational opportunity, take aggressive action on climate, and make housing, paid leave, and child care accessible and affordable. The budget resolution — though we had hoped it would go even further — is an essential part of acting on that mandate given to us by the American people. This vote is a major step for making a historic investment to rebuild our country and make people whole after the devastation of the past year and a half.

 

“Yes, we need a substantial investment in our hard infrastructure like roads and bridges. But roads and bridges can’t serve people if they don't have the child care they need in order to go to work or the health care they need to stay healthy and participate in the workforce. Roads and bridges can’t serve us if they’re continually eroded by a worsening climate crisis. We need to invest in our people and a livable planet if we want to build an economy that works for everyone. 

 

“I look forward to working with my colleagues over the next month to ensure that the full $3.5 trillion reconciliation package is passed with or before the bipartisan infrastructure bill. Let’s get this done and fulfill our promise to the American people. “

 

NYS Office of the Comptroller DiNapoli Announces Reduction in Employer Contribution Rates for Retirement System

 

State Pension Fund is 99.3% Funded, One of the Best Funded in the U.S. 

 New York State Comptroller Thomas P. DiNapoli today announced reductions in employer contribution rates to the New York State and Local Retirement System (NYSLRS) for both of its systems – the Employees’ Retirement System (ERS) and Police and Fire Retirement System (PFRS). The adjusted rates will impact payments next State Fiscal Year 2022-23. In addition, DiNapoli lowered the long-term assumed rate of return on the Fund’s investments from 6.8% to 5.9%.

“The Fund’s strength gives us the ability to weather volatile markets. Our prudent strategy for long-term, steady returns helps ensure our state’s pension fund will continue to be one of the nation’s strongest and best-funded,” DiNapoli said. “While the reduction in employer contribution rates is welcome news for taxpayers, our investment decisions are always made based on what is best for our 1.1 million working and retired members and their beneficiaries.”

The estimated average employer contribution rate for ERS will be lowered from 16.2% to 11.6% of payroll. The estimated average employer contribution rate for PFRS will be reduced from 28.3% to 27% of payroll. According to the Fund’s Actuary’s estimates, the expected total employer contributions for Feb. 1, 2023 are $4.4 billion, which is $1.5 billion less than the expected employer contributions during the same period for 2022 – the lowest level since 2011.

This marks the fourth time that DiNapoli has lowered the state pension fund’s assumed rate of return as economic and demographic conditions have changed. In 2010, he decreased the rate from 8% to 7.5%, in 2015 to 7% and in 2019 to 6.8%.

The median assumed rate of return among state public pension funds is 7.0% as of August 2021, according to the National Association of State Retirement Administrators. Thirty-four out of the 133 state public pension plans listed had assumed rates of return of less than 7%. There are plans that have a fiscal year end date of June 30, 2021 and many have already announced intentions to lower their assumed rates of return further.

DiNapoli also announced the funded ratio of the state pension fund is 99.3%.

The state pension fund’s annualized rates of return are 11.17% over the past five years, 9.19.% over 10 years, 7.65% over 20 years and 8.96% over 30 years.

Employer rates for NYSLRS are determined based on investment performance and actuarial assumptions recommended by the Retirement System’s Actuary and approved by DiNapoli. A copy of the Actuary’s report can be found here.

In 2012, DiNapoli began providing employers with access to a two-year projection of their annual pension bill. Employers can use this projection in the preparation of their budgets. Projections of required contributions vary by employer depending on factors such as the types of retirement plans they adopt, salaries and the distribution of their employees among the six retirement tiers.

There are more than 3,000 participating employers in ERS and PFRS, and more than 300 different retirement plan combinations.

Payments based on the new rates are due by Feb. 1, 2023, but employers receive a discount if payment is made by Dec. 15, 2022.

Report

Annual Report to the Comptroller on Actuarial Assumptions

About the New York State Common Retirement Fund 

The New York State Common Retirement Fund is the third largest public pension fund in the United States with estimated assets of $268.3 billion as of June 30, 2021. The Fund holds and invests the assets of the New York State and Local Retirement System on behalf of more than one million state and local government employees and retirees and their beneficiaries. The Fund has consistently been ranked as one of the best managed and best funded plans in the nation. The Fund's fiscal year ends March 31.

Air Quality Health Advisory Issued for Long Island and New York City Metro

 

In Effect for Thursday, Aug. 26, 2021

 New York State Department of Environmental Conservation (DEC) Commissioner Basil Seggos and State Department of Health (DOH) Commissioner Dr. Howard Zucker issued an Air Quality Health Advisory for the Long Island and New York City Metro regions for Thursday, August 26 from 11:00 a.m. until 11:00 p.m.

 

The pollutant of concern is: Ozone 

 

The advisory will be in effect 11 a.m. through 11 p.m. 

 

DEC and DOH issue Air Quality Health Advisories when DEC meteorologists predict levels of pollution, either ozone or fine particulate matter are expected to exceed an Air Quality Index (AQI) value of 100. The AQI was created as an easy way to correlate levels of different pollutants to one scale, with a higher AQI value indicating a greater health concern. 

 

OZONE 

 

Summer heat can lead to the formation of ground-level ozone, a major component of photochemical smog. Automobile exhaust and out-of-state emission sources are the primary sources of ground-level ozone and are the most serious air pollution problems in the northeast. This surface pollutant should not be confused with the protective layer of ozone in the upper atmosphere. 

 

People, especially young children, those who exercise outdoors, those involved in vigorous outdoor work and those who have respiratory disease (such as asthma) should consider limiting strenuous outdoor physical activity when ozone levels are the highest (generally afternoon to early evening). When outdoor levels of ozone are elevated, going indoors will usually reduce your exposure. Individuals experiencing symptoms such as shortness of breath, chest pain or coughing should consider consulting their doctor. 

 

Ozone levels generally decrease at night and can be minimized during daylight hours by curtailment of automobile travel and the use of public transportation where available. 

 

New Yorkers also are urged to take the following energy-saving and pollution-reducing steps: 

• use mass transit or carpool instead of driving, as automobile emissions account for about 60 percent of pollution in our cities;
• conserve fuel and reduce exhaust emissions by combining necessary motor vehicle trips;
• turn off all lights and electrical appliances in unoccupied areas;
• use fans to circulate air. If air conditioning is necessary, set thermostats at 78 degrees;
• close the blinds and shades to limit heat build-up and to preserve cooled air;
• limit use of household appliances. If necessary, run the appliances at off-peak (after 7 p.m.) hours. These would include dishwashers, dryers, pool pumps and water heaters;
• set refrigerators and freezers at more efficient temperatures;
• purchase and install energy efficient lighting and appliances with the Energy Star label; and
• reduce or eliminate outdoor burning and attempt to minimize indoor sources of PM 2.5 such as smoking. A toll-free Air Quality Hotline (1-800-535-1345) has been established by DEC to keep New Yorkers informed of the latest Air Quality situation. 
  

Additional information on ozone and PM 2.5 is available on DEC's website and on DOH's website.  

The Thursday, Aug. 26, Air Quality Health Advisory regions consist of the following: Region 1 Long Island, which includes Nassau and Suffolk counties and Region 2 New York City Metro, which includes New York City, Rockland, and Westchester counties.

Brian Benjamin new Lieutenant Governor

 

Brian Benjamin new Lieutenant Governor

The Harlem Democrat could help the new governor make inroads with downstate voters.

The selection of the Manhattan legislator, first reported by NY1 Wednesday morning, means more diversity than ever at the upper echelons of government – state Comptroller Thomas DiNapoli is now the only white man in a statewide office – while also adding some downstate balance for Hochul, a Western New York native, as she gets ready to run for reelection next year. The newly installed governor will announce her pick at a Thursday event in Harlem, according to The City. 

A new gig as lieutenant governor offers Benjamin a second chance to move on from the state Legislature midway through his third term in office. He came in fourth in the 2021 Democratic primary for New York City comptroller in June, with 7.7% of the vote. He will be the second Black man to serve as lieutenant governor of New York.

State Sen. Jamaal Bailey, also rumored to be in the running, congratulated Benjamin in a tweet Wednesday. “As we reimagine New York, we continue to move forward with the best. Huge congrats to my brother @NYSenBenjamin and his wonderful family on this well-deserved appointment,” Bailey wrote.

As printed in City and State.

133 Days and Counting - Where are you Staten Island Chuck

 

Here I am in Staten Island with my good friend James Oddo the Staten Island Borough President. Did you know he is a Republican? He is the only Republican borough president, and Staten Island wants to secede from New York City. I don't know why, because the city just put in a new ferry for them.

Things are a little different in this borough from the other boroughs, there are no real tall buildings that we can fill them up with Democrats, just old homes with land and Republicans. Did you hear that my developer friends homes with big yards and driveways. We can always change the zoning to whatever you want, and by the way I am exploring a race for governor. If I run for governor, I will need lots of money to win, but that has never been a problem for me. Just look at all those new buildings in Manhattan, the Bronx, Brooklyn, Queens, and we must build up Staten Island, and make it a majority Democratic borough like the other four boroughs. 

Stay cool today and hydrated. 

Brooklyn Business Owner Charged with Bank Fraud, Identity Theft and Witness Tampering

 

Defendant Allegedly Deposited More Than $55 Million into Shell Bank Accounts and Used the Funds to Purchase Jewelry, Make Payments on Luxury Vehicles and Renovate His Penthouse Apartment

 A complaint was unsealed in federal court in Brooklyn charging David Motovich, principal of a lumber and construction materials business, with bank fraud, aggravated identity theft and witness tampering.  Motovich was arrested this morning and will make his initial appearance before United States Magistrate Judge Roanne L. Mann this afternoon. 

Jacquelyn M. Kasulis, Acting United States Attorney for the Eastern District of New York, Michael J. Driscoll, Assistant Director-in-Charge, Federal Bureau of Investigation, New York Field Office (FBI), and Thomas Fattorusso, Acting Special Agent-in-Charge, Internal Revenue Service-Criminal Investigation (IRS-CI), announced the arrest and charges.

“As alleged, the defendant used a seemingly legitimate, family-run business as a front for engaging in a $55 million check cashing scheme that deliberately flouted federal banking and anti-money laundering laws.  Further, as law enforcement was closing in on his schemes, Motovich attempted to derail the government's investigation by tampering with witnesses,” stated Acting U.S. Attorney Kasulis.  “Today's arrest demonstrates that this Office will take down and vigorously prosecute defendants like Motovich, who circumvent compliance with federal financial laws out of greed, just to line his own pockets and live a life of luxury.”  Ms. Kasulis also expressed her appreciation to the U.S. Attorney’s Office for the District of New Jersey for their assistance with the case.

“Federal banking laws exist to protect the industry from fraud and the general public from money laundering schemes that often further criminal activity. Motovich, as alleged, broke these laws in order to advance his own monetary interests,” stated FBI Assistant Director-in-Charge Driscoll.  “To make matters worse, he’s also accused of tampering with government witnesses.  Rest assured this type of illegal behavior will be aggressively pursued by the FBI and our partners.”

“The multiple schemes Mr. Motovich allegedly devised has great impact on both his clients and the United States treasury,” stated IRS-CI Acting Special Agent-in-Charge Fattorusso.  “In our current environment, the services provided by federal and local governments are sorely needed.  The allegations in this complaint require the financial expertise IRS-CI provides in order to unravel the complexities of such crimes.”

As alleged in the complaint, since at least 2012, Motovich has operated an illegal check cashing business from his office at his family-run lumber business located in the Midwood section of Brooklyn.  The customers of Motovich’s illegal check cashing business are primarily the owners and operators of construction companies who pay their employees in cash to avoid having to pay state and federal employment taxes, including taxes owed under the Federal Income Contributions Act.  As part of the scheme, Motovich cashed millions of dollars of checks for his customers in exchange for a fee or a percentage of the face amount of the checks, ranging between four and 10 percent.  Motovich’s customers paid a higher fee to Motovich than the fees charged by licensed check cashing businesses because the customers understood that Motovich would not file Currency Transaction Reports for cash transactions in amounts greater than $10,000 or Suspicious Activity Reports, as required by federal anti-money laundering statutes.  Motovich supplied his check cashing customers with fraudulent documents that they could use to disguise the transactions as payments by the customers for materials and/or subcontracting work if the customers were audited by the New York State Workers Compensation Board or tax authorities.      

In furtherance of his scheme, Motovich created shell companies for the sole purpose of facilitating his illegal check cashing business and instructed his customers to issue checks drawn against their business accounts and make the checks payable to one of the companies.  Motovich then deposited the checks into bank accounts that he created at several financial institutions.  To conceal his control and ownership of the funds in the accounts, and to avoid detection of his scheme, Motovich opened the accounts in the names of other individuals.

In total, between 2012 and 2019, Motovich deposited more than $55 million into the accounts that he had opened in the names of other individuals and used the funds to purchase real estate; pay personal and corporate credit card accounts; purchase luxury items, including millions of dollars of diamonds, watches, jewelry and clothing; make lease and purchase payments for Porsche and Lexus luxury vehicles; pay premiums on multi-million dollar life insurance policies for himself, his wife and others; make renovations to his penthouse apartment; and to fund other business ventures.

When Motovich became aware of the government’s investigation, he tampered with witnesses by encouraging them not to cooperate with the government, including encouraging them to fire their attorneys and retain attorneys that he had handpicked for them, and by paying at least one witness and that witness’s family members so that the witness would not cooperate with law enforcement.  

The charges in the complaint are allegations, and the defendant is presumed innocent unless and until proven guilty.

Brooklyn Federal Jury Convicts U.S. Citizen of Attempting to Provide Material Support to ISIS

 

Defendant Traveled from the United States to Tunisia in 2016 With the Goal of Crossing into Libya to Join the Islamic State

 A federal jury in Brooklyn convicted Bernard Raymond Augustine, a U.S. citizen and California resident, of attempting to provide material support to a designated foreign terrorist organization, the Islamic State of Iraq and al-Sham (“ISIS” or “the Islamic State”).  The verdict followed a one-week trial before United States District Judge Sterling Johnson, Jr.  When sentenced, Augustine faces up to 20 years in prison.

Jacquelyn M. Kasulis, Acting United States Attorney for the Eastern District of New York, Mark J. Lesko, Acting Assistant Attorney General of the Justice Department’s National Security Division, Michael J. Driscoll, Assistant Director-in-Charge, Federal Bureau of Investigation, New York Field Office (FBI), and Dermot F. Shea, Commissioner, New York City Police Department (NYPD), announced the verdict.

“The defendant’s unvarnished testimony at trial demonstrates his ongoing support for ISIS and its glorification of barbaric acts of terrorism, including attacks on U.S. soldiers, the enslavement of Yazidi women and mass killings, which he described as ‘cool,’” stated Acting U.S. Attorney Kasulis.  “Today’s guilty verdict underscores the strong commitment of this Office and its law enforcement partners to combatting terrorism and protecting the United States from potentially dangerous threats to its national security.”

The evidence at trial established that in February 2016, the defendant traveled from San Francisco, California to Northern Africa, with the goal of joining ISIS, a designated foreign terrorist organization.  In the months leading up to his travel, the defendant watched ISIS propaganda, including videos glorifying ISIS’s violence, such as “The Flames of War.”  The defendant conducted internet searches for, among other things, “how to safely join ISIS,” and reviewed websites related to ISIS recruitment practices, including one titled “How does a Westerner join ISIS? Is there a recruitment or application process?” 

Augustine also posted numerous statements in support of ISIS and violent extremism on the internet.  He posted statements such as “the Islamic State is the true Islam,” “Muslims who leave the west . . . answer the call for the struggle, and march until they are victorious or martyred are the true believers,” and the ISIS caliphate “can’t be established and maintained except through the blood of the mujahideen who practice the true belief.” 

Augustine then purchased a one-way airplane ticket and traveled to Tunisia so that he could present himself as a willing participant in ISIS’s terrorist activity.  After arriving in Tunisia, Augustine was detained by local authorities before he could make it to ISIS-controlled territory across the border in Libya.  He was subsequently returned to the United States in 2018, where he was brought to the Eastern District of New York for prosecution. 

Augustine represented himself at trial with the assistance of standby counsel.  The defendant took the witness stand in his own defense and his testimony included the following statements:

• “I just want to tell the jury that I do not regret my decision, I’m proud of my decision and if I could go back and start over I would do it again, and if I became a free man tomorrow I would do it again, I would leave and I would do that again.  I have no regrets about it and I’m proud of it.  And I believe that all Muslims must immigrate to the Islamic State upon its establishment, especially ones living in the west.”

• Augustine testified that he was aware that Islamic State fighters slaughtered members of the Yazidi ethnic group, and that he understood that the Islamic State enslaved Yazidi women.  
• Augustine described the Islamic State propaganda film “Flames of War,” which he acknowledged contains mass killings, as “a really cool video.  You should watch the whole thing.”
• Augustine testified that Islamic State propaganda showing holy warriors fighting and engaging in martyrdom and suicide bombings was “cool” and “hell, yeah, it was cool.”